Question: We are working to understand the new Treasury Office of Foreign Assets Control “Framework for OFAC Compliance Commitments.” for evaluating the effectiveness of a compliance program. What are some of the key takeaways?

A: OFAC enforces trade and other sanctions against foreign countries and other designated entities. The key point of OFAC’s Framework is that the compliance function must actually work, not simply exist, says compliance expert Matt Kelly on his Radical Compliance blog. 

The agency’s new guidance says, “Senior management commitment to supporting an organization’s compliance program is a critical factor.” 

That means, first, having a…